4 New Categorical Standards Being ConsideredHealthcare IndustryUnused Pharmaceuticals“Best practices” (i.e., BMPs) being developed for Hospitals and Long Term Care FacilitiesDetails to be released withFinal 2010 ELG Plan

10 Revisions to Existing Standards Being ConsideredOCPSF/Inorganics/Pharma Mfg – Parts 414/415/439Chlorine and Chlorinated Hydrocarbons (CCH) ManufacturingMercury…increases due to new air pollution controls in mercury-cell process to manufacture :ChlorineCaustics

18 FOG Programs and Pretreatment: Regulatory BasisWhat is an Industrial User?40 CFR 403.3(j)An industrial user is a source of indirect discharge.What is an Indirect Discharge?40 CFR 403.3(i)Introduction of pollutants into a POTW from any non-domestic source regulated under section 307(b), (c), (d) of the Clean Water Act.All non-domestic sources regulated by Pretreatment Standards require a control mechanism. 40 CFR 403.8(f)

20 FOG Programs and Pretreatment: Regulatory BasisSpecific Prohibitions (b)The following pollutants shall not be introduced into a POTW:403.5(b)(3)Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW resulting in Interference.403.5(b)(4)Any pollutant at a flow rate or concentration that will cause Interference with the POTW.

21 FOG Programs and Pretreatment: Regulatory BasisWhat is a POTW?40 CFR 403.3(q)A treatment works owned by a municipality. This definition includes any devices or systems used in the storage, treatment, recycling, and reclamation of municipal sewage or liquid industrial wastes. It also includes sewers, pipes, and other conveyances that convey wastewater to a municipal treatment plant.What is Interference?40 CFR 403.3(k)A discharge, either alone or in combination with discharges from other sources, which both:(1) Inhibits or disrupts the POTW (see above); it’s treatment or operations, or sludge management(2) Causes a violation of any POTW permit requirement

22 FOG Programs and Pretreatment: Regulatory BasisPOTW permit requirements:…shall at all times properly operate and maintain……shall implement approved pretreatment program and Part 403…

23 The receiving sewer serves a commercial fast-food area. Is the source of this pollutant an industrial user?

24 Can this pollutant cause Interference with the POTW, and therefore a violation of Pretreatment Standards?

25 Do the industrial users that supply this pollutant require a control mechanism by the POTW Pretreatment Program?

26 FOG Programs and Pretreatment: Regulatory BasisWhat about residential sources? They are domestic sources…Control also necessary to meet common goals:Meet proper O&M condition of NPDES permitPrevent sewer overflow violationsAuthorities for controlling domestic FOG sources are local